As a recipient of Sponsored Agreements, MUSC must have systems and procedures in place to ensure compliance with applicable regulations (OMB Circular A-21, Section J.10) concerning the documentation of the distribution of salaries and fringe benefits charged to sponsored programs and facilities and administrative (F&A) cost activities.

Additionally, as a recipient of Medicare/Medicaid funds, MUSC is required to document clinical and hospital administrative activities in order to comply with Medicare/Medicaid Cost Reimbursement requirements.

3. How do I know if I am covered by the After-the-Fact Activity Reporting System?

The following monthly-paid employees are covered by the system:

All University Faculty, except faculty with 100% effort in instruction.

All other University personnel who;

Cost share or directly charge activity to one or more sponsored agreements.

The distribution of salaries and wages for biweekly-paid employees is documented separately by MUSC's electronic time reporting system, manual time cards, or manual time sheets. No further certification or documentation is required in accordance with Circular A-21.

4. What are my responsibilities if I am covered under the After-the-Fact Activity Reporting System?

Review and electronically certify your online Quarterly Activity Report within sixty (60) days of each quarter end date.

Provide a reasonable estimate of the distribution of your activities by activity category (see category definitions) for each each UDAK Project that funded his/her salary and fringe benefits for the quarter.

Inform your supervisor or responsible official during the quarter if the distribution of salary charges should be modified based on a significant change in your activities.

5. What are my responsibilities as an effort coordinator?

Inform covered employees when the Online Activity Reports are available for review and certification.

Ensure that the reports are electronically submitted to GCA by the stipulated due date.

Notify the Departmental Business Manager or other appropriate departmental personnel if significant variances (greater than +/- five percent) are reported between the employee's effort percentages by UDAK project and the actual distribution of payroll charges by UDAK project.

Maintain adequate documentation to substantiate any changes to an employee's salary distribution that will meet internal and external audit requirements.

6. Why must Average Hours per Work Week be reported on the Activity Report?

If an employee reports activity in any of the clinical categories (Incremental Teaching/Clinical Time, Clinical Instruction, Clinical Services, Classroom Instruction or Hospital Admin), then the employee must provide an estimate of Average Hours per Work Week in order to meet Medicare/Medicaid Cost Reporting requirements.

7. What is a PEAR Form?

PEAR = Position Employee Action Request Form.This form is subitted by the Business Manager to establish and change personnel actions (salary, position, FTE percentage, etc.) as well as establish distribution of salaries and fringe benefits by UDAK project in the payroll and financial accounting systems.

8. Does my Business Manager need to submit a new PEAR Form every time I have a variance on my quarterly Activity Report?

If a significant change on the Activity Report is necessary to reflect actual effort of an employee, then the Business Manager must submit retroactive adjustments to salaries and fringe benefits charges via an updated PEAR Form in accordance with Procedure 4-3.12: Initiating a Cost Transfer to/from a Sponsored Project. Although there is no precise definition for the term "significant", it has been construed as a general rule that a change applicable to a given project or activity of 5% or more of an employee's total effort warrants an adjustment. These adjustments should be implemented immediately following the employee's certification of the Activity Report.

Recognizing that workload requirements for projects and activities may vary from quarter to quarter, a significant change of greater than +/- 5% that is expected to average out to the budgeted level of effort over the course of the current fiscal year will not require retroactive salary adjustments.

9. What happens if I don't submit my Activity Report?

Activity Reportsare considered delinquent if not completed within 60 days after the due date. Sponsored Projects UDAKs listed on any delinquent activity reports will be subject to suspension of expenditure privileges, including personnel charges, until all delinquent reports are submitted.